121 Payroll Services: Anti-Bribery Policy (UK Bribery Act 2010)

At 121 Payroll Services Ltd, we are committed to conducting business in an honest, ethical, and transparent manner. This anti-bribery policy outlines our zero-tolerance approach to bribery and corruption in all forms. We are dedicated to upholding the principles of the UK Bribery Act 2010, which applies to conduct both within the UK and abroad.

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What Is Bribery?

Bribery refers to offering, promising, giving, requesting, or receiving an inducement or reward in exchange for gaining an improper advantage. This can include:

• Giving or offering a bribe

• Receiving or requesting a bribe

• Bribing a foreign public official

121 Payroll Services Ltd can also be held liable if we fail to prevent bribery by an associated person acting for our benefit.

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Purpose of This Anti-Bribery Policy

This anti-bribery policy demonstrates our commitment to complying with the Bribery Act 2010 and other relevant laws. We take a strong stance against bribery and corruption, ensuring that all business dealings are carried out professionally and fairly, with integrity and transparency.

Scope and Applicability

This policy applies to all individuals working for or on behalf of 121 Payroll Services Ltd, including employees, directors, officers, agency workers, contractors, and third-party representatives (collectively referred to as "workers").

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What Is Not Acceptable?

Under this anti-bribery policy, it is unacceptable for any worker to:

• Offer, promise, or give any payment, gift, or hospitality in exchange for an improper advantage

• Accept payments, gifts, or hospitality with the expectation of providing improper advantages

• Facilitate or request "kickbacks" or "grease payments"

• Engage in activities that may breach this policy

Facilitation Payments and Kickbacks

We strictly prohibit facilitation payments or kickbacks in any form. If asked to make a payment, employees must ensure it is lawful, proportionate, and recorded appropriately. Any concerns about payments must be reported immediately.

Gifts, Hospitality, and Expenses

This anti-bribery policy allows reasonable and appropriate gifts or hospitality to maintain good business relationships or market services, provided they:

• Are not intended to influence business decisions improperly

• Comply with applicable laws

• Are recorded transparently and proportionately

Record-Keeping

We maintain accurate financial records and internal controls to demonstrate compliance with this policy. All gifts, hospitality, and payments must be documented, including the business rationale behind them.

Responsibilities and Raising Concerns

Preventing, detecting, and reporting bribery is everyone’s responsibility. Workers are required to report any suspected breaches of this policy, including being offered or asked to give a bribe. Breaches may result in disciplinary action, including dismissal or contract termination.

Training and Communication

All workers receive training on this anti-bribery policy, and our zero-tolerance approach is communicated to clients, suppliers, and business partners where appropriate.

Monitoring and Review

121 Payroll Services Ltd regularly reviews and updates this anti-bribery policy to ensure its effectiveness in preventing bribery and corruption. Workers are encouraged to provide feedback and disclose any risks or concerns. Together, we can uphold the highest ethical standards and ensure compliance across our operations.